Jackson v. Deft, Inc.
1990 Cal. App. LEXIS 1010, 273 Cal. Rptr. 214, 223 Cal. App. 3d 1305 (1990)
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Rule of Law:
The military contractor defense does not shield a manufacturer from state tort liability for failure to warn unless the government's specifications for warning labels created a significant conflict with state law by prohibiting the manufacturer from adding more comprehensive warnings.
Facts:
- Larry Jackson worked as a civilian painter for the U.S. Navy at Mare Island Naval Shipyard and Alameda Naval Air Station from 1975 to 1985.
- During his employment, Jackson was exposed to polyurethane paint products containing toluene diisocyanate, which he alleged caused him to develop asthma and other disabilities.
- Deft, Inc. (Deft) and Koppers Company, Inc. (Koppers) manufactured these paints and supplied them to the Navy.
- The paints were produced according to military specifications that included specific language for the warning labels.
- Both Deft and Koppers also sold the same or substantially similar paint products to commercial, non-military customers.
- A Koppers vice-president testified that the military's labeling specifications were considered minimum standards and that the company was free to add additional warnings.
- A Deft vice-president testified that their labels included what the Navy required, as well as other information from their trade association and suppliers, suggesting the Navy's control was not absolute.
Procedural Posture:
- Larry Jackson filed a personal injury complaint against Deft, Inc., Koppers Company, Inc., and other defendants in a California trial court.
- Deft and Koppers moved for summary judgment, asserting the military contractor defense and the adequacy of their warnings as a matter of law.
- The trial court granted the summary judgment motion in favor of Deft and Koppers.
- Larry Jackson, as the appellant, appealed the trial court's judgment to the California Court of Appeal.
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Issue:
Does the military contractor defense shield manufacturers from state tort liability for failure to adequately warn when the government-provided specifications for warning labels constitute minimum requirements but do not prohibit the manufacturer from adding additional warnings?
Opinions:
Majority - Strankman, J.
No. The military contractor defense does not shield manufacturers from liability where there is no significant conflict between federal contract requirements and state law duties. The defense applies only when the government's specifications are so precise as to prohibit the contractor from complying with its state-law duty to warn. Here, the evidence suggests that the military specifications for the paint labels were merely minimum standards and did not prevent Deft or Koppers from adding more comprehensive warnings. Testimony from company executives indicated they could, and sometimes did, add information beyond what the military specifications required. Because the contractors could have complied with both their contractual obligations and the state-prescribed duty of care, there is no significant conflict with federal policy that would justify displacing state tort law. Therefore, a triable issue of fact exists as to whether the defense applies, making summary judgment improper.
Analysis:
This decision significantly clarifies the application of the Boyle military contractor defense to failure-to-warn claims. It establishes that the defense is not a blanket immunity for government contractors; instead, the contractor bears the burden of proving a 'significant conflict' between federal requirements and state law duties. For a failure-to-warn claim, this means showing the government's control over the warning's content was exclusive and prohibitive, not merely a set of minimum guidelines. This ruling makes it more difficult for contractors to obtain summary judgment on such claims and preserves a path to recovery for individuals injured by products used by the military where the manufacturer could have provided a better warning without violating its contract.
